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UNITED STATES P j,,.. h N'UCLEAR REGULATORY COMMISSION
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MEMORANDUM FOR:
Darrell G. Eisenhut, Director Division of Licensing FROM:
Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
SUBJECT:
" INDEPENDENT REVIEW" BY PG&E CONTRACTORS (RECORD SEARCH)
As you requested in your note of January 4,1982, we'have searched the subject in the transcripts of the PG&E meetings of October 9 and November 3,1981, and in the tnnsparencies for the Commission briefing on November 9,1981 (closed meeting. Attachment 1 is a sumary of the staff's discussions during those meetings on the subject of " independent review" (requirements, scope and definitions). Attachment 2 is a copy of the pages and transparencies cited in the summary.
I The subject of " independent review" was discussed frequently during those meetings but to a lesser degree or not with respect to its definition.
We have the appropriate transcript pages available at your request.
b Sck.
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Robert L. Tedesco, Assistant Director for Licensing Division of Licensing Enclos ures :
As stated e
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ATTACHMENT'l y
Summary of Record Search.for " Independent Review" - Requirements, Scope.and Definition l.
PG&E Meeting 10/9/81 Staff did not specifically request an independent review. Based on presen-l tation in meeting by R. ~ Cloud of his plan for an " independent review" ithe-staff assumed that.the review would be independent (page 120)
" Independent review".was not defined or characteriz*ed by:PG&E or by staff; H. Brown requested that for the review to-be-independent.it should not be' funded by PG&E (pages 120,121)
.2.
PG&E Meeting 11/3/81 Staff inquires and raises questions on " independent review" (pages 208, 214, 216, 236, 237)_
Staff characterizes independent review as " sensitive issues" and to mean
-" independent of people who did the original review, as a minimum, and to be done outside the PG&E design organization" (pages 216, 254, 255, 262)
Staff expands scope of independent review of seismic related activities to include design verif.ication of all safety related other service contracts (pages 253, 254 and 3 pages of typed specifics provided to PG&E at end of meeting) 3.
Commission briefing 11/9/81 Staff requires independent and complete reverification and identifies scope lof such review (2 transparencies)
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-ATTACHMENT 2 J
r Transcript Pages (PG&E Meetings on October 9 and Novembar 3,1981) 1 and Transparencies (Comission Briefing on November 9,1981) on Subject of
" Independent Review" e
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UNITED STATES OF A.tERICA 2
NUCLEAE REGULATORY C0f.XISSION MEETING WITH PACIFIC CAS AND ELECTRIC CCM?ANY 4
TO DISCUSS SEISMIC DESIGN REVIE7, DIAELC CANYCN UNI! 1 5
6 Nuclear Regulatery Comcissien 7
Recr. P-112 7920 Norfolk Avenue 8
Sethesda, Zaryltad 9
Friday, October 9, 1991 10 The meeting convened at 9:05 a.m.
11 NRC STAFF PRESENT:
12 H.
DENTON D.
EISINHUT 13 R. VOLLMER B. EUCXLEY 14 V.
OLMSTEAD J. KNIGHT 15 E. JORDAN B. FAULKENBERRY 16 D. KIRSETT P. KUD 17 F. SCHAUER R. TEDESCO 18 S. BOSNAK 19 PEESENT FEDE PACIFIC G AS AND ELECTRIC CO.
20
- 3. SHACKELFORD N. NORTON 21 D.
BRAND R. BETTINGER 22 J.
HOCH H. TRESLER
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23 R. CLOUD J. SCHUYLEE D
24 J.
ELOOM J. ROCCA 25 E.
ESSELMAN ALDER 5CN REPCRTING COMP ANY. INC.
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.12.o 1,the Llikolihcod of an undetected ' error in the 'seis:ic 2 analysis or design is greatly reduced."
3 What.ve find today is tha t-despite perha ps the 4 Staff 's best efferts, we had some ve ry substantial 5 undetected errors that came up after an operating license 6 vas issued.
f And for that reason, on behalf cf the people that 8 live arcund the plant, I would like te urge the Staff to 9 take a very ca ref ul look at - the : vork FG T.I i s doin g, a t the to quality assurance program.
And I voeld lik e t o r equ est tha t 11 th e Staff recommeed an independent audit of the seismic 12 r ea nalys is.
13 ER. DENTON:
.I think we are getting an independent 14 a u d it.
I' assume we are getting an independent audit through_
15 the work tha t Dr. Cloud is doing.
That is one-reason I 16 vanted the re ve rifi ca tion program plan submitted, so ve can 17 look at it in advance to see if we think it is really 18 a de qua te.
And I would certainly velcome any comments you 19might have on that plan after we have had a chance to see it 20 f ro m the company.
And we vill have our own look at these 21 sa m e are as, of course.
l 22 MR. EROWNt Harold, let te follow up en that.
I 23 am not sura if maybe David is sa tisfied.
But to the extent 24 that an independent audit ought to be pursued, it realli 25 ought to be what we would consider independ ent, at least to l
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Jol9(si 1 the ' extent.to whi:h the governor would be coefortahle.
It 2 would be an audit that is not being done by PGt.E or through 3 PGEE's f unding.
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4 And I say this not casting any doubts on Er.'
5' Cloud 's in te grity or his ca pability.
I stipulate those frc:
6 the beginning.
It is just that the natural inclination of
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7 people who have studies' and audits done by these whc have~
8 been found to have committed an error is not to take 9 necessarily with the same enthusias: an audit the way they 10 would if done by' nn findependent pa rty ret being 'f unded by 11 that individual or party that com:itted the errer.
12 And that is about as gent y and a s trunca ted a 13 sentence as I:could use to try to show as much respect as I 14 can to Dr. Cloud, because, as I said, I am not in any way
- 15 challenging his qualifica tions or his integrity, and I 16 stipulate those to begin with.
17 But I think a party that does not have either an 18 int erest or a sour:e of funding from the parties interested 19 in the q uestion --
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20 HE. DENTONa I think I understand the peint you 21 a re making, and we vill certainly take it under advisement.
22 ER. TLEISCHAKERa I want to make it perfectly l
23 clear that we are not accusing PGEE of dissembling here, and i
l 24 ve are not accusing the Staff either.
It is re ally a 25 question that we have got everybody here that shares the ALDERSON REPORTING CouPANY,INC.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
3 DIABLO CANIdN SEISHIC RE7IE7 4
5 Room P-116 6
Phillips Building 7950 Norfolk Avenue 7
Bethesda, Ma ryland 8
Tuesdar, Nov ember 3, 1981 9 PRESENT4 to E. JORDAN H. DENTON 11 D. EISINHUT B. BUCXLEY 12 R. VCLLMER R. DE YOUNG
-13 J. CRE75 R. FAULXENBERRY 14-J. XNIGHT f
F. MIRA0LIA 15 On behalf of the NRC 16 R. RUBBARD H. BROWN 17 On behalf of Intervecors l
18 C.
MANIATIS l
B. NORTON 19 D. BRAND
- 7. RA!!OND 20
- 7. GANGLOEF R. CLOUD 21
- 7. GHIO R. 9ETTINGER j
22
- 3. TRESLER l
J. BLUME l
23 On behalf of PGE.E N.-
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1 hoped that the entire nuclear desics process with its 2 margins and its requirenents vould be enough that any of the 3 errors that one would expect to find in a review of a lot of
- 4 calculations vould not affect safety.
And I believe tha t
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5 that is the situation that we find ou'eselve s.in now at.the 6' noment.
_Ve do not find the basic safety of the plant 'has 7 been compromised, _but ve have fould instances. of
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8 aisapplication.of seismic data.
Thank you.
9 NH DeYOUNG:
May I ask a question?
Why did you_
10 hope you wouldn't find large errors that would impose upon p
l 11 saf e ty ?
Whr did you hope that?
I could see why the utility
.12 vould hope that, but as an infependent r Jviewer, Thy did you 13 hope that? _
g 14 3R. CLOUD:
I'm speaking as a professional
-15 e ngineer 16
- 23. DeYOUNG:
Sometimes if you hope for something, 17 you direct your activities toward that hope.
It's a strange is statement for an independent reviewer.
i 19
- 33. YOLLMER:
Bob, getting back to some of the
- 20. errors that you found_, I's curious, vare these found because 21 you re-did the calculations or because the design i-i.
22 documentation was so good you can go back and find very I
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-23 specifica117' where the error occurred?
24
,33.: C103D:
Our vork up to nov has been based upon i
25 the review of the applicability of the data.
We checked the AL.0ER$CN PEPCAUNo CCMP ANY. INC.
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1 vere not changed to indicate that this analysis could be 2 used for Unit 1 if you so chose.
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3 Durine the design process of the supports in Unit I
42it was. decided to change the anchor design in Unit 2 from-5 vhat we had in Unit 1,
and they changed the' anchor to allov'
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6 rotation but anchored it to prevent any translational l
1 7 aovement.
When that rhange was made it berase ne'cessary to 8 rerun that Unit 2 thermal analysis which was used for Unit 2 p.
9 and Unit 1, to properly nodel the anchor.
Th'e analysis was 10 rerun and issued, and the previous Unit 2 analysis vas i
i 11 cancelled.
12 eoctunately, the pipe designers recognized that F'
13 since it was specific to Unit 2 and that it modeled a 14 dif f eren t anchor configuration, they should continue to use.
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15 the cancelled previous Unit 2 analysis for Unit 1, and ther 16did.
So tne desi;n was proper.
17
- 53. DENTON:
Do ve have a report fron yoc on 18 this ?
All the things you just mentioned?
19
- 53. CREWS:
We do have an LE2.
I think we have ii
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20 the initial report.
21 3R. THE5LE2:
I have described it as to Region 5, i
22 r e s.-
23 3R. DENTON:
1st me sove back to an issue that we 24 sta rted on and tha t's the degree of independence of De'.
25 Clo u d.
Teil us who in the ervui ation he ceports to.
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215 Il{s{st-1 ER. MANEATIS:
I was going to add tha t Dr. Cloud 2 doesn't report to anyone in our organiration.
He has been 3 retained to do an independent and indepth reverifica tion.
4
- 33. DENTON :
Who gives his his directions as to 5 scope?
6 ZR. 3ANEATIS:
As I'had earlier indicated, Mr.
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- 7. Brand, a uc' Vice President of Engineering, is directing this 8 whole investigation and re-analysis progras.
And he, with 9 his.subo'edinates has retained his to make this independent 10 investigation.
11
- 13. C100D:
If I could add something.to that, I 12 would say the program that I presented was ba sed en all 2r 13 own ideas, and I formulated it'ayself without any help from 14 the people at PGCE.
b 15 ER. MANEATIS:
And I vould further comoent that on 16 the basis of his findings that he reported in his interis 17 report, I think it is clear that his review is objective.
t 18 ER. DENION:
Do we get the sas4 reports he gives 19 you ?
20
-32. HANEATI5:
Yo u jus't' g o t' - i t.
And I have to-21 say, 3r. Denton, that soae of these things have just been 22 disclosed to.te, so you got it almost the same time I did.
23
- 33. EISENHOT:
When v.111 ve be expecting to see 24 tha t short-tern repo rt, Bob Cloud said it's essentially t
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25 respleta.
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1 ER. NORTON:
Dr. Cloud, could you answer that?
2 3R. CLOUD:
I believe it's -- ve vill be turning 3 it in either this week or n ext, so you should have it' 4 shortly thereaf ter.
5 MR. NORTON:
I might add we do not have it.
It's 6 not a question of us evievise it.
We don't have it, 7 either.
It just hasn' t been done yet.
8 MR. DENTON:
Well, since this is a particularly 9 sensitiv.e issue, I was vond ering how you propose to handle 10 rossents on this draft, or are you going to send us the same 11 report he sends you and add you cover letter to it?
Or hov 12 Twill you preserve independence?
13 XR. N3RION:
Well, like any other natter, I'n a 14 little bit concerned about suddenly there b eing questions 15 abo ut the independence of the reviev.
The NEC has.cetained 16 a consultant and-the sane question nigh t be asked -- vell 17 gee, how do ve know that review is independent?
I mean, 18 there is no reason to believe this review isn't independent.
19
.3R. DENTON: -I'm-just asking.hov independent i s : i t.._ _ _ -
l 20 3R. NORTON:
Any suggestions you have -- if you 21 v an t the caport before ve see it, fine.
I frankly resent 22.the inp'11 cation that Dr. Cloud is not an in dependent i
23 reviewer because he is.
As Mr. Kaneatis just reported to l
24 you, we heard this presenta tion to you yesterday -- in fact, l
25 ve heard it Sunds/ for the first time.
I assure you that 's
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'll El 1 service con tracts during this period of inte:est, -four of i
t' 2 which you described.
The other.eight vould be looked at y'
3 under the seismic reverification program.
And in addition, 4 then, you wearing your QA hat vill look a t all tvelve?
5 3R. RAYHOND:
Yes.
6 5R. DENTON:
For evidence of controls?
7 3R. RAYMCND:
Yes.
8 3R. DENTON:
During that period.
9 NR. RAYMOND:
Yes.
10
'38. DE IOUNG:
Again coine b=ek to in' doe =Me--
11_ review, you have two safor programs underwa y: _ one, the 12 verifica tion progra m with D r. Cloud, someone from outside. -
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13 completely independent; the other thing is the CA check frocr r
- 14. vithin the com pany.
Did you consider going outsid'e to get 15 an independent chack of tha t?
16 ER. NORTON:
No.
The nature of quality assurance 17 program and audit is such that we believe v ery stror. gly that 18 ICE and, for that satter, NRR can easily ve rif y our audit.
, tg It is the vaty' nature of the paper ~ trail, the audit is going 20 to be done and, of course, crea te -its own p aper -t:sil.
And -
21 ve belie ve the NRC can easily satisfy itself of the extent 22 or depth of the audit and the accuracy simply by
' 23 spatchecking without a great deal of input on the NRC's 24 p a r t.
.25 3R. DE YOUNG:
Dr. Cloud said he had spent about a 2
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1 thousand sac-hours to date.
Eov many man-hours have you 2 spent on your part of it?
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3 43R.3AYF.OND:
The question was hov sany san-hours-4 have ve expended on the inforsation we have identified to 5 date; righ t?
6
- 12. DE YOUNG:
Ye s..
7 3R. RAYEOND:
Let me do some sental arithmetic 8 cr.s ! quick.
Approximately 250 to 300 san-hours.
9
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- 32. DENTON:
Do you report to any organization?
10 XR. HAYMONDs The vice president of nuclear power 11 generation.
12
- 33. DENTON:
Is this independent'.then of the-13 organizational units that you are auditing?
f.
14 3R RAYMOND:
Yes.
15 XR. DENTON:
You say different person than just 16 head of tha enginsecing staff?
17
- 32. RAY 3OND:
Yes, he is.,. Don Brand is vice 18 p re s'id e n t of the angineering department.
Mr. Schuyler is 19 the vice president of nuclear power generation.
Two
. 20 differen t distinct people.
21-3R' DENTON:
I would like to touch on just a fev 22 other cleanup issues here.
I d'o not want to put Cr. 31oon 23 on the spot.
But I will anyway, since he is quite capable 24 of answe ring any questions in his field.
'25 ~
I Vonder, do you have an7 c5mnents you vould like I
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t 1 like to reiterate-tha: ve feel the N3C is fully capable, as 2 it has, to continu_e es avaluate tha t.
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5
- 33. DI ITON:_ Thank you.
6 In the period since ve met, Dick De Young and 1 t
7 and our staffs have set to reflect on what we heard this 8 morning and what we have ga thered by direct discussion ove,r 9 the last three weeks, and we have come to some conclusions to about the scope an[d extent of your activities th a t I think 11 in some respects would substantially broaden the extent of 12 design verification.
13 Let se talk about these areas.
One area our view t'
~ is wha t you are 14 s till h a sn ' t chan; red on, and I'think that 15 now embarked, on _.- you reseaber last time ve indicated we 18 thought you should do an independent review and verifica tion 17 of all the seismic related activities prior to fuel loading, 18 and the results oE this should be forwarded to us, and any 19 modifications thati that program requires should either be 5ade or it should be justified to us before you be permitted 20 21 to load fuel.
I thindour views on that are the same, and I 22 23 think the Cloud approach substantively vill be addressing 24 that issu e.
So I think with regard to the activities 25 requiring fuel loading you are embarked on a progras that i
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1 satisfies what ve think should be done in that area.
2 And what I see you doing, just to restate, I see r
3 an independent design reverifica tion being done in all 4 seismic design related areas.
That includes the eight 5 service type contractors.
So I thin'k in that area what we 6 are stating is not dif f eren t than what 've said la st time.
7 I think where ve do differ is what else needs to 8 be doce beyond that.
It seems to us that before ve can make 9 a determination about going above 5 percent power, assuming 10 tha t the seismic design verification program had been f
11 completed, that the scope of discovery was not any larger, 12 and its modifications required had been made, we think you 13 need a similar independent design ' verification o f all the 14 safety related other service contracts.
L Ihe other four that you mentioned, you had -
15 16 proposed to do,a Q A check on those which, in our viev, vould 17 onlr go partvar toward addressing the problem.
I think 18 those other four service related contracts should have the 19 saae sort of in-depth independent design ~ verification.
2 One meaning of the word " independent" for se is 21 independen t of the people who did the original work, and 22 Whe ther that was done by your existing contractor, Dr.
23 Cloud, o c some o the r gro up, it seems to me in order to be 24 valuable it has got to be done more or less outside your 25 design o rgrnization.
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Excu se m e, Mr. Dento n.
I as not sure 2 rou intended to say what I thought I heard you say., but I 3 have hea rd other people say it.
D r. Cloud has not vorked 4 for PGCE before on this project.
Someone said he was a 5 consultant *before.
That is not so.
l 6
- 33. DE3 ION:
No, I was t rying not to say that he 1
8 7 vouldn' t be suitable.
I was saying that it didn't have to 6 be Dr. Cloud but a similar effort like that don,e by his or s
9 soceone who is independent of the de sign activities rela ted
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to to those four other service type contracts.
t 11 Secondly, and I think the bigger effort, will be i
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1 12 to conduct a similar -- and for the area I just mentioned, i
13 these four other service related contracts, I think it
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14 should be to the same depth that is being done on the first 7
15 eight.
I think there has been -sufficient doubt about the 16 formality of the inforsation with regard to service 17 rentracts that you should do that not only for the eight you 18 ha v e started, but for the other four.
19 Now, I think on the sampling ba sis you need ~ to do 20 an independent design verification of ?GCZ's own internal 21 design activities which ve vere no t able to establish this 22 sorning that thera were internal organirational situa: ions 23 or procedures that somehow precluded so=e of this
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24 informalitT to get into your own internal pcocess.
So I H
25 would think you need an effort cos; ara,ble to what we have t
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- 33. J03D AN :
I think you could clarify that by 1
I 2 saying those reports vould not substitute f or your technical iI -
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- 33. N0aION:
We also have-5255(d) for Unit 2.
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5 These vo uld be in addition to that.
6 d3. DENICN:
We tried to 2:ite this dava in plain.
7 language as opposed to requistory language.
f 8
(General laughter.)
9
- 53. DENION:
And we vill pass these around for 10 people interested.
11 It might be veil if you spend a moment to take a 12 look at it.
- 32. NO3 TON :
Excuse me.
Earlier I said that Dr.
13 r
14 Cloud had not been a consultant befoce.
What I meant was 15 not during any of_the,tiseframe that all this was going on.
16 He was involved in a seismic systers interaction program that 17 vas done for the AC35,. and since sacebody pointed out when I 18 said he was not s consultant before, what I was thinking of 19 was during this -tisef rame v e-are talking about, '76,
'77, 20 ' 7 8, and I believe late '79 when th e seismic system 21 interaction program was going on.
22 ER. DENTON:
I appreciate the cla rifica tion.
23 I quess just to reiterate, my viev of independence 24 vould mean as a minimuy_,you are not teviewing the work with u
25 which you vera associa ted.
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1.
Licensee Activities Prior to Fuel loadino Conduct an independent [ design review and verification of all safety i
related activities performed under the PG&E-URS/31ume c:.Lract as they relate to the Hosgri reanalysis. This review should address the development, accurancy, transmittal, and use of information both within PG&E and within URS/Blume, as well as the transmittal
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of information between PG&E and URS/Blume as related to the s
require'ments of NRC Quality Assurance Criteria (10 CFR part 50, Appendix B). The 'results of this verification program should be provided for NRC review.
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' The errors that have been-identified to date, as relate to performance
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of activities conducted.udner this contract, should be addressed as regards to basic cause and impact upon final design. Also, any new errors or deficiencies identified should be appropriately addressed in the review and subsequent report.
i In addition, any modifications that are required 'as a result of the I
current and newly identified problems must be completed prior to a
fuel loading unless specific exceptions are approved by NRC.
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Licensee Activities Prior.to. Exceeding SJ cower Ooeration a)
Conduct an independent design review and verification of all safety related structures, systems, and ccmponents that
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received design input information or data developed by PG&E service-related contractors prior to June 1,1978. T.his review should address all activities involved in the development, accuracy transmittal, and use of safety-related information, both within the PG&E organization and within each contractor's organization, as well as the transmittal of information between PG8E and each contractor, as related to the requirements of NRC Quality Assurance Criteria.
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b)
Conduct an independent design sampling review and verification of PG&E internal design activities that have been performed on
-Diablo Canyon Unit 1 that related to the development of the design of safety related structures, systmes, and c:mponents.
i The extent of this review should be that which is necessary to confim that the PG&E quality assurance controls described in their QA Manual and associated procedures since 1970, and as related to the implementation of NRC Quality Assurance Criteria have been fully and effectively it@lemented.
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Conduct an [ independent design sampling review and verification of all PG&E service related contractor work that was developed subsequent to January 1,1978 and that has. Seen or will be used as input into the design of safety related structures, systems,
.and' components. The extent of this review should be that which is necessary to confirm that the contractor and PG&E quality assur'ance controls and procedures that were in effect during this time period were fully and effectively implemented. The review should address all interface activities associated with the work, both internal to. the contractor and within PG&E, as they relate to NRC Quality Assurance Criteria L.*
y Provide the results of this verification program for NRC review. Any l
modification required as a result of this program shall be ccmpleted prior to exceeding 5% power unless speicife exemptions are approved
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by NRC.
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FRANK MIRAGLIA h
492-7243 1
_11/09/81 4,
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1 NOVEMBER 9, 1981.
1 COMMISSION BRIEFING ON 1
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}gj{ligRAGLIA RAll LJ1/09/81.
PG&E' REVERIFICATION PROGRAM PROPOSED BY STAFF (SUBJECT OF 50.54F LETTER) o PRIOR TO-FUEL LOAD AND' OPERATION UP T0' 5%. POWER 2-INDEPENDENT AND COMPLETE REVERIFICATION OF Al1 -
SAFETY-RELATED ACTIVITIES PERFORMFD BY URS/RillME k.IMPACTOFALLERRORSDETEC~iEDONFINAL DESIGN EVALUATED AND REANALYS'IS DOCUMENTED IN TECHNICAL REPORT ALL APPLICABLE MODIFICATIONS TO FACILITY DESIGN
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RESULTING FROM REANALYSIS AND REVERIFICATION EFFORTS BE COMPLETED o
PRIOR T0. EXCEEDING.5%. POWER s....
INDEPENDENT AND COMPLETE DESIGN REVIEW AND REVERIFICAT OF ALL OTHER PRE-JUNE 1978 SERVICE-RELATED CONTRACTS
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INDEPENDENT AND SAMPLlHG REVIEW AND-REVERIFICATION OF PGEE INTERNAL DESIGN ACTIVITIES
-- INDEPENDENT AND SAMPLlHG REVIEW AND REVERIFICATION OF POST-1978 SERVICE CONTRACTS _
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ALL APPLICABLE MODIFICATIONS TO FACILITY DESIGN RESULTING FROM. REANALYSIS AND1REVERIFICAT10N. EFFORTS ~. :
BE COMPLETED L. >. e ' & _. ^.ee.eme.eee. e -
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FRANK MIRAGLIA 492-7243 11/09/81 PG&E REVERIFICATION PROGRAM _ PROPOSED BY STAFF -
(SUBJECT OF 50.54F LETTER) CONTINUED o
PG8E TO PROVIDE:
DETAILED PROGRAM PLAN FOR CONDUCT OF INDEPENDENT j
-DESIGN REVERIFICATION PROGRAMS DESCRIPTION OF QUALIFICATION OF PERSONNEL AND CONTRACTORS PERFORMING INDEPENDENT DESIGN REVERIFICATION PROGRAMS 4
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